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Private debt collection

Corporate Tax Planning

Inspector General Identifies Issues with IRS’ Private Debt Collection Program

Earlier this year, the Internal Revenue Service (IRS) launched a new private debt collection program, and outsourced debt collection over certain accounts to four private contractors. More than 500,000 accounts consisting of more than $4.1 billion in outstanding debts were part of the program. Recently, the Treasury Inspector General for Tax Administration (TIGTA) identified a number of issues with the program. Program Introduced by Congress The program was authorized under Section 32102 of… Read More

Voluntary disclosure

Corporate Tax Planning

The End of IRS’ Voluntary Disclosure Program is Imminent

Earlier this year, the Internal Revenue Service (IRS) announced that it would begin to ramp down the 2014 Offshore Voluntary Disclosure Program (OVDP) and the program would be fully closed by September 28, 2018. The Offshore Voluntary Disclosure Program The OVDP initially launched in 2009, with a second program offered in 2011, and then 2012. The current program launched in 2014. These voluntary disclosure programs have enabled American taxpayers… Read More

Money Laundering

Litigation

The Standard of Conduct the CRA Must Uphold in an Audit

Last week, we reviewed a decision in which the Canada Revenue Agency (CRA) was ordered to pay $5 million in damages after a court found that the Agency had engaged in a number of questionable practices during the “Billionaire’s Audit” targeting high net worth Canadians in the mid-2000’s. This week we explore the standard of conduct that ought to apply during any audit undertaken by the CRA. The Quebec Superior Court examined… Read More

Audit

Litigation

CRA Ordered to Pay $5 Million After “Unreasonable” Audit

The Canada Revenue Agency (CRA) was recently ordered to pay damages of almost $5 million after two men representing a group of taxpayers sued the agency claiming that the CRA engaged in “abusive” practices during an offshore tax audit which the men were caught up in. In a lengthy decision supporting the damages order, the Quebec Superior Court admonished the CRA for a number of questionable practices that took place during the… Read More

NAFTA

Corporate Tax Planning

Canadian Government Speaks to Washington About Thousands of Canadians Affected by U.S. Tax Reforms

CBC News reports that the Canadian government is in discussions with Washington about the impact of the Republican’s Tax Cuts and Jobs Act. Retroactive Repatriation Tax Part of the U.S’ $1.5 trillion tax overhaul package was a one-time retroactive Transition Tax, also known as the Repatriation Tax. This provision was intended to discourage U.S. multinational companies, such as Microsoft and Apple, from leaving their money in foreign subsidiaries. However, this provision is… Read More